Groups
Challenge EPA's Approval of Dow's Sulfuryl Fluoride: EPA allows 5 times
higher levels for infants than adults
(Beyond Pesticides, March 30, 2004) On March 22, 2004,
the Fluoride
Action Network (FAN) formally challenged US EPA's approval of Sulfuryl
fluoride for use as a fumigant on a wide variety of foods.

EPA identified fluoride
as the major toxicological endpoint of concern for exposure to Sulfuryl
fluoride. In its Risk Assessment, which served as the basis for approval,
EPA made an unprecedented decision to allow an acceptable dosage for
infants (0.571 mg/kg bodyweight/day) which is five times higher than
for adults (0.114 mg/kg/day).

The Washington,
DC-based Beyond Pesticides joined FAN in submitting Written Objections
and a Request for a Hearing, the process necessary to formally challenge
EPA's decision.

This is the first
time that Sulfuryl fluoride, produced by Dow AgroSciences, has been
approved for food use. In its approval, EPA set the highest levels of
fluoride residues "in or on food" in US history. As a fumigant
it will be used on over 40 foods that include nuts, dried fruit, rice,
wheat, barley, etc. Fumigants are used to kill the bugs that infest
and destroy stored foods.

Sulfuryl fluoride
is Dow's alternative to Methyl bromide, the ozone-destroying food fumigant
that has a phase-out deadline of January 1, 2005, for developed countries.

FAN says there are
alternatives available to Methyl bromide and Sulfuryl fluoride (both
made by Dow) which would allow the US phase-out date to be met. And
because alternatives are available, it is unnecessary to allow anyone,
particularly the workers who will spray it, to be put at such risk.

EPA alters
safety standard

According to Paul
Connett PhD, Executive Director of FAN, and Professor of Chemistry at
St Lawrence University in Canton NY, "EPA's data showed that some
children were already receiving more fluoride than EPA's existing safety
standard allowed. Such a situation should have been grounds for rejecting
Dow's request to add an additional source of exposure to the diet."

However, instead
of denying Dow's request, the EPA has opted to increase the tolerable
dose for children.

Since children are
already receiving excess fluoride from sources such as fluoridated water,
toothpaste, and processed foods, Connett states that "EPA was basically
faced with one of two choices: reject Dow's request or loosen the safety
standard. The EPA chose the latter option."

"The science
does not support EPA's decision to again support corporate greed instead
of children's health," said Jay Feldman, executive director of
Beyond Pesticides, a Washington-DC based national clearinghouse and
advocacy organization. He continued, "It is time for the Bush Administration
to stop using EPA to support pollution and poisons for political benefit."

"Unprecedented":
EPA sets higher safe dose for infants than adults

EPA's move has left
scientists familiar with risk assessment shaking their heads. In loosening
the safety standard for children, EPA has created a situation where
the acceptable dose for infants is five times higher than the acceptable
dose for adults.

According to Connett,
"We feel this is an unjustified and unprecedented decision by EPA,
which runs counter to their mandate under the Food Quality Protection
Act (FQPA) to set standards that are more protective of children, not
less."

According to Chris
Neurath, Research Associate with FAN: "If EPA's pesticide division
had followed their statutory mandate they should have set a standard
for children ten times more protective than for adults. Instead they
have brazenly manipulated normal protocol and assigned a sensitivity
for infants that is 5 times less protective! For infants to be deemed
less sensitive than adults is unprecedented."

"There is every
reason to believe that children are more sensitive to fluoride than
adults," notes Connett. "EPA has cited no new data to justify
its decision. We find this to be completely unacceptable."

Several senior scientists
at EPA concur.

Speaking on condition
of anonymity, senior scientists at EPA - familiar with pesticide risk
assessment - explained to FAN that they "have not seen any case
where an acceptable dosage for children is higher than for adults."

"EPA's action
is irresponsible," they declared.

Profits
for Dow, Risks for the Public

"We are deeply
concerned," says Connett. "Based on the near epidemic rate
of dental fluorosis in our children, it is clear that fluoride exposures
need to be reduced, not increased."

Dental fluorosis,
a mineralization disorder of teeth, is caused by excess ingestion of
fluoride during a child's teeth-forming years. The condition is now
seen in up to 50% of children in fluoridated areas, and in some children
requires expensive cosmetic treatment.

But dental fluorosis
is not FAN's only concern.

"The fortunate
thing about dental fluorosis is that we can see it. We can see the white
spots on a child's tooth and say 'yes, fluoride has caused cellular
damage in that tooth.' But what about the internal organs - the ones
we can't see?" asks Connett.

Recent reseach indicates
that fluoride accumulates in the pineal gland, which is located between
the two hemispheres of the brain. EPA knows that the pineal, an endocrine
gland, contains hydroxyapatite (the same as bone) and that fluoride
has been found to accumulate to even greater levels in the pineal than
in the bone. The pineal gland produces the hormones melatonin and seratonin.

According to Connett,
"Animal studies indicate that fluoride lowers the production of
melatonin. One of the risks we may be taking by exposing our whole population
to fluoride is interfering with delicate regulatory timing processes,
from the onset of puberty to the aging process. However, EPA has chosen
to ignore this concern."

Risk to
Workers

Workers are at risk
not only from the acute toxicity of Sulfuryl fluoride but also the potential
for brain, lung, kidney, and bone effects.

Results reported
from animal studies (rats, mice, dogs, rabbits) exposed to Sulfuryl
fluoride all share these effects: holes in the brain, necrosis of the
brain, and effects on the white matter of the brain (particularly the
female species). These results, which come from tests performed by Dow
scientists, are not without their limitations. Researchers did not test
male rats in acute neurotoxicity tests. In subchronic neurotoxicity
tests, the examination of nervous system tissues were only performed
on the highest dosed animals, while a developmental neurotoxicity study
has yet to be performed.

Over the past 4
years, the Fluoride Action Network has been working to raise awareness
about recent research indicating the potential for human harm from current
fluoride exposures.

According to FAN,
a growing body of research suggests that fluoride may be associated
with several serious health problems, including arthritis, hip fractures,
bone cancer, kidney damage, infertility, and brain disorders.

"There is a
profound need for precaution on the fluoride issue, and yet a profound
absence of it exists in Washington," adds Connett.